John Alfred Laszloffy - Page 5

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               Section 6331(a) provides generally that, if a taxpayer                 
          liable to pay Federal taxes neglects or refuses to pay the same             
          within 10 days after notice and demand, it shall be lawful for              
          respondent to collect such tax by levy upon all property and                
          rights to property belonging to the taxpayer.                               
               Section 6331(d)(1) requires that, prior to making a levy on            
          a taxpayer’s  property, respondent must give to the taxpayer                
          written notice of the proposed levy and written notice of the               
          taxpayer’s right to a hearing.                                              
               In such a hearing, respondent is required to verify whether            
          the requirements of all applicable laws and administrative                  
          procedures have been met and to consider other issues raised by a           
          taxpayer including appropriate spousal defenses, collection                 
          alternatives, and challenges to the appropriateness of the                  
          collection actions.  Sec. 6330(c).                                          
               Section 6330(c) also requires respondent to consider whether           
          respondent’s proposed collection action balances the need for               
          efficient collection of taxes with the taxpayer's legitimate                
          concern that any collection action be no more intrusive than                
          necessary.  Sec. 6330(c)(3).                                                
               Under section 6330(c)(2)(B), if a taxpayer received a notice           
          of deficiency for a year in question, in a later collection                 
          hearing the taxpayer may not contest the existence or amount of             








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